Sailing Along – Significant Changes to the IMDG Code 37-14

By September 10, 2014 January 29th, 2020 Regulation Updates, IMDG

The next edition of the IMDG Code will soon be available for use in January 2015, becoming mandatory in January 2016. This amendment sees additions (some of which are also incorporated into IATA – see Suzanne’s Blog of August 28th) to the DG list adding UN numbers for adsorbed gases and capacitors; and re-naming air bag modules/seat belt pretensioners to “Safety Devices”.

The latter will have 2 designations: “electrically initiated”, UN3268 (Class 9); or “pyrotechnic”, UN0503 (Class 1.4) depending on the classification. Parts 1, 2, 4 & 6 update Class 7 requirements for radioactive materials. These additions and changes require a series of modifications to the other parts of the Code.

The GHS reference has been updated to the 5th edition and the revised CSC International Convention for Safe Containers (including criteria for taking units out-of-service) has been added to the General Provisions in Part 1.

Column 16 in Part 3 (“the DG list”) has been split into “a)” and “b)” with the addition of new provisions in Part 7, to list codes and for stowage (“SWxx”- 7.1.5)/ handling (“Hxx” – 7.1.6) and Segregation (“SGxx” – 7.2.8) respectively. This modified system also results in a series of consequential changes throughout the other sections.

Required training for shipping DG by sea »

As expected, there is an exemption for Marine Pollutants in quantities of 5L/5kg, or less, net per package or inner container.

Part 5 requires that the “Overpack” and “Salvage” markings must be at least 12mm high. Fumigation label dimensions are increased to at least 400 mm wide x 300 mm high (from 300 x 250). Letters of shipping names on portable tank CTUs of less than 3000 L capacity may reduced to a minimum of 12 mm high.

Provisions for shipping damaged lithium batteries for recycle or disposal have been added.

PP1 has been relaxed to allow use of non-closed vehicles on Ro-Ro ships if the vehicle has secure “fencing” to the full height of the cargo.

Special provision SP367 allows the use of the single name “paint related material” to be used when paint and paint related material are consigned in the same package. SP367 also applies to the equivalent case with printing ink/printing ink related material.

Details of these and other changes are posted on the IMO website » Default.aspx

Order your copy of the new code from ICC today! »

Clifton J. Brown

Clifton J. Brown

Clifton Brown has over 35 years of practical experience in the Canadian chemical and manufacturing industries. He has worked in research, quality, environment, health and safety in a range of industries including explosives, pesticides, manufacturing/contract packaging, pharmaceuticals, and specialty chemicals. This experience has provided a basis for dealing with a variety of regulatory approaches that have been useful in implementing and evaluating/auditing compliance. This experience has also been useful in effectively helping others to understand and apply the regulations in a North American context. Clifton represents ICC on the RDC regulatory and safe operations committees, participates in Transport Canada consultations and attends WSPS, CSSE and related activities.